Good morning. My name is Albert Strunk. I am an obstetrician-gynecologist and Vice President, Fellowship Activities with the American College of Obstetricians and Gynecologists (ACOG).
I am very pleased to be here today to represent ACOG, an organization of 44,000 physicians specializing in health care for women. The College is grateful for the opportunity to offer comments on the adoption of ICD-10-CM as the standard code set for reporting diagnoses. Accurate diagnosis coding is critical to improving the quality of health care, informing decisions about public health policy, and facilitating smooth processing of health insurance claims. ACOG believes that ICD-10-CM represents a significant improvement over ICD-9-CM for these purposes. We support adoption of ICD-10-CM as the standard code set.
The World Health Organization introduced ICD-10 in 1993. Many other countries use ICD-10 based systems for reporting both mortality and morbidity statistics. Our continued reliance on an ICD-9 based system for morbidity statistics inhibits the free flow of data that is essential to international medical research and disease surveillance. The U.S. recently began to use ICD-10 for mortality statistics. Establishing congruence between morbidity and mortality reporting would enhance tracking of outcomes and identification of effective interventions.
It has been almost three decades since ICD-9-CM was introduced. During that time our medical knowledge has expanded greatly, as has the range of treatments offered. Obstetric care provides several examples of this rapid pace of change. Developments in sonography have revolutionized the examination of the fetus. The ability to make genetic diagnoses has changed dramatically in the last 30 years and will change exponentially over the next 10 years. Our understanding and clinical use of maternal and fetal physiology in the management of labor has improved significantly. Knowledge and classification of important maternal conditions such as diabetes mellitus and hypertensive diseases of pregnancy has also changed. ICD-9-CM is woefully inadequate to capture these changes.
NCHS staff and the Coordination and Maintenance Committee have been very responsive to ACOG recommendations for changing the obstetric chapter of ICD-9-CM to meet current needs. However, the ability to change and expand ICD-9-CM has been stretched to its limit. Any further expansion will be difficult. ICD-10-CM offers greatly enhanced capabilities for identifying and tracking important obstetric conditions and interventions. These data are needed for high-priority public health efforts to reduce adverse pregnancy outcomes.
I would like to highlight four specific aspects of ICD-10-CM that will facilitate reporting of issues of growing importance in obstetric care. First, the addition of a fifth digit to report the trimester of pregnancy should prove valuable in efforts to monitor the provision of prenatal care and the occurrence of complications. ICD-9-CM does not allow for identification of trimesters. ICD-10-CM also responds to the growing prevalence of multiple pregnancy by permitting identification of individual fetuses in a multiple gestation. This will make it possible for the first time to link a condition to a specific fetus. In addition, ICD-10-CM includes expanded codes for reporting abnormal findings on antenatal screening. The range of screening tests offered or recommended to pregnant women continues to expand. These screening tests generate additional episodes of care, which require appropriate diagnosis codes. None are now available. Finally, ICD-10-CM will include a category for care provided to the fetus due to abnormalities.
There are several challenges and potential disadvantages to adopting ICD-10-CM. Physicians, hospitals, coders, and payers will need to learn a new system. Also, the six-digit ICD-10-CM codes will dictate that computer systems and software be reconfigured. The costs associated with training and computer changes will not be trivial. In an environment of declining reimbursement and increasing regulatory demands, physicians, hospitals, and other health care providers should not be expected to bear the entire burden of these costs alone. Planning for implementation of ICD-10-CM must address cost issues.
On balance, ACOG believes that the benefits offered by ICD-10-CM are substantial enough to justify the costs and disruption its adoption will inevitably entail. I appreciate having the opportunity to present ACOG’s views today and I especially want to note the College’s appreciation for the manner in which NCHS collaborates with the physician community. We are eager to work with NCHS in developing plans for educating physicians about ICD-10-CM and addressing barriers to its implementation. I would be happy to respond to your questions.